Both of these changes look good to me. It's a bit difficult to isolate them
in the whole-file diff; it would be great if each of these changes came
with its own standalone diff, but I totally understand the difficulty of
disentangling all of that.

Aaron

On Thu, Apr 23, 2026 at 3:16 PM 'Ben Wilson' via
[email protected] <[email protected]> wrote:

> All,
>
> This thread begins discussion of proposed updates to the Mozilla Root
> Store Policy (MRSP) relating to CA operational reporting in a "timely
> manner" (Issue #292 <https://github.com/mozilla/pkipolicy/issues/292>)
> and alignment of the MRSP with external policy frameworks (Issue #293
> <https://github.com/mozilla/pkipolicy/issues/293>).
>
> These changes are intended to improve clarity and consistency in how CA
> operators meet their reporting obligations, particularly with respect to
> the CCADB, and to better align MRSP requirements with the CCADB Policy and
> the CA/Browser Forum’s requirements documents. The goal is to reduce
> ambiguity, eliminate overlapping or inconsistent requirements, and
> reinforce expectations for CA reporting of accurate and current operational
> data.
>
> Again, here is a comparison
> <https://github.com/mozilla/pkipolicy/compare/3b7d84f5c9708cf6be9655319825d60ea338eca4...ad8e1766be6e0e9a93a64b0b71506ae923086ec5>
> of the proposed MRSP v3.1
> <https://github.com/BenWilson-Mozilla/pkipolicy/blob/3.1/rootstore/policy.md>
> (working draft, subject to change) vs. the current MRSP v3.0
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>
> .
>
> *Overview of Proposed Changes*
>
> *Reporting Obligations and Timeliness – #292
> <https://github.com/mozilla/pkipolicy/issues/292>*
>
> Section 7.3 (Removals) is updated to replace the existing reference to
> failure to act in a “timely manner” with more explicit language tied to
> CCADB and policy compliance expectations.  Under the proposed revision:
>
> “Repeated failure to provide required notifications or updates in the
> CCADB, or to otherwise comply with Mozilla or CCADB Policy requirements for
> maintaining accurate and current information, SHALL be grounds for
> disabling a CA operator’s root certificates or removing them from Mozilla’s
> root store.”
>
> This change is intended to:
>
>    - Align the MRSP with the CCADB Policy, which already defines
>    expectations for timeliness and data maintenance, and hence avoid
>    maintaining separate or potentially inconsistent timing requirements within
>    the MRSP; and
>    -
>
>    Emphasize that ongoing accuracy and completeness of operational data
>    is a core compliance obligation.
>
>
> *2. Policy Alignment and Order of Precedence – #293
> <https://github.com/mozilla/pkipolicy/issues/293>*
>
> Clarifications are added to address how the MRSP interacts with other
> applicable requirements, including the CCADB Policy and CA/Browser Forum
> guidelines.
>
> A new sentence in section 2.1 provides an order of precedence. In the
> event of inconsistency between the MRSP and other applicable requirements,
> the MRSP takes precedence. However, where the MRSP does not explicitly
> resolve an inconsistency, then the most restrictive applicable requirement
> applies, unless otherwise specified.
>
> Additionally, where the MRSP had more specific or duplicative text, it was
> removed if the subject was already addressed in the CCADB Policy or
> CA/Browser Forum requirements.
>
> These changes are intended to:
>
>    - Provide a clear framework for resolving conflicts across multiple
>    governing documents;
>
>
>    - Reduce redundancy within the MRSP; and
>
>
>    - Rely on external policies where they already define detailed
>    operational requirements, while preserving Mozilla’s authority to impose
>    stricter or additional requirements where necessary.
>
>
> Feedback on the proposed direction and suggestions on the draft language
> are welcome.
>
>
>
> Thanks,
>
> Ben Wilson
>
> Mozilla Root Program
>
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